[DOE LETTER HEAD]
July 23, 2008
The Honorable A.J. Eggenberger
Defense Nuclear Facilities Safety Board
625 Indiana Avenue, NW, Suite 700
Washington, D.C. 20004-2901
Dear Mr. Chairman:
This is in response to your March 17, 2008, letter regarding your concerns on the increased contribution of manufacturing defects to the rejection rates of filters tested at the Filter Test Facility (FTF). Specifically, your letter requested a report on (1) actions planned by the Department of Energy (DOE) to investigate and correct the root cause of increased rejection rates of High Efficiency Particulate Air (HEPA) filters at the FTF, (2) actions planned by DOE to assess the potential degradation of critical quality program components supporting HEPA filter manufacturing attributes that are not explicitly tested at the FTF (e.g., resistance to pressure and heated air, water repellency, tensile strength), and (3) actions planned by DOE to reassess the adequacy of those non-safety-related HEPA filters providing radioactive material confinement in DOE nuclear facilities that are not subjected to 100 percent testing at the FTF, given the relatively high rejection rates observed during 2007.
The Office of Health, Safety and Security convened a working team made up of DOE Federal and contractor employees, an outside expert and FTF personnel experienced in the use, testing, and qualification of HEPA filters. On May 8, we requested additional time to respond to your letter in order to allow the assembled working team to conduct further discussions with filter/filter media manufacturers and more analysis of the available information. The working team has now developed the attached document which outlines the actions planned by DOE to address the above three issues. An overview of the actions planned was presented to your staff on June 24, 2008.
If you have any questions or concerns, please contact me at (301) 903-3777 or your staff may contact Andrew Lawrence, Director, Office of Nuclear Safety, Quality Assurance, and Environment at (202) 586-5680 or Subir Sen, Office of Quality Assurance Policy and Assistance at (301) 903-6571.
Glenn S. Podonsky
Chief Health, Safety and Security Officer
Office of Health, Safety and Security